John G. Goettee, Jr. and Marian Goettee - Page 7




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          June 16, 1982) in the amount of $807.38.  Respondent did not                
          credit petitioners’ 1979 account with interest for the period               
          June 16 through June 28, 1982.  On June 13, 1983, when respondent           
          refunded to petitioners the overpayment petitioners claimed on              
          their 1982 tax return, respondent did not credit petitioners’               
          1982 account with interest for the period June 1 through June 13,           
          1983.                                                                       
          B.  The Tax Court Proceeding and Surrounding Circumstances                  
               On October 15, 1986, respondent sent to petitioners a notice           
          of deficiency, in which respondent made adjustments on account of           
          TEA items and determined deficiencies and additions to tax as               
          shown in table 1.                                                           
                                       Table 1                                        
                                                                                     
                                        Additions to Tax                              
          Sec.          Sec.         Sec.                                             
          Year    Deficiency     6653(a)(1)     6653(a)(2)     6659                   
          1978     $14,607          $730     –-             $4,382                    
          1979       8,208           410           --          2,462                  
          1981       9,537           477            1       2,861                     
          1982       8,129           406            2       2,439                     
          1  50 percent of the interest due on $9,537.                                
          2  50 percent of the interest due on $8,129.                                
               Respondent also determined that petitioners’ deficiencies              
          are subject to an increased rate of interest under section                  











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